“Non-public” information is any confidential information concerning Albemarle or its affairs (extending to customers, suppliers and business transactions). Information is considered to be “material” if a reasonable investor would be likely to take the information into account when deciding whether to buy, sell or hold Albemarle securities. Any information that could be expected to affect the price of Albemarle securities, whether it is positive or negative, should be considered material. There is no bright-line standard for assessing materiality; rather, materiality is based on an assessment of all of the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight.
By way of example, material non-public information can include information about topics such as sales, earnings, projections, corporate developments, new products, research projects, impairments, layoffs, acquisitions, divestitures, financings, joint ventures, threatened or actual litigation, and other business matters concerning customers, suppliers or other companies with whom the Company does business or has relationships.